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Reduce
REDUCE OR MINIMIZE THE
or
HAZARDOUS WASTES YOU GENERATE
Minimize
R
The following examples ecycling and pollution prevention measures can significantly reduce your regulatory
show hazardous wastes burden and might save your facility considerable money. This section presents informa-
typically generated by tion on hazardous wastes typically generated by various motor freight and railroad
the motor freight and transportation processes and provides suggestions for how to recycle them or imple-
railroad transportation ment pollution prevention measures. Some tank cleaning operations, for example, have
industry, including self-contained small parts washing systems that do not drain to the sewer. These systems might
shipping and leasing
include a solvent dispenser, wash basin, and waste solvent collection system. Hazardous waste generat-
companies that own
ed by these commercial operations may be returned to the supplier who redistills the cleaning fluid
and clean tank cars,
and disposes of the remaining hazardous waste. Switching to nonhazardous aqueous-based solvents
and the tank car clean-
ing industry. The exam- for small scale cleaning operations, however, will reduce the amount of hazardous waste you generate.
ples provide sugges- Solvent recycling can also decrease hazardous waste production from small parts cleaning.
tions for how to recycle, Only the federal hazardous waste codes are provided here. Your state might have different codes for
treat, or dispose of haz-
some waste streams. You should check with your state hazardous waste authority for additional waste
ardous waste according
codes and requirements.
to federal regulations.

PROCESS Unloading and Cleaning Tank Trucks and Rail Cars

Wastes Generated Acid or alkaline cleaners, ethyl benzene, residuals (heels) from shipment of product or haz-
ardous waste, residues from wastewater treatment, spent solvents, volatile organic emis-
sions, and wastewater.

Possible RCRA D001 (residuals, solvent wastes), D002 (cleaners, residuals, wastewaters), F003 (ethyl ben-
Waste Codes zene), F and K waste codes (residuals from shipment of F- and K-listed waste), and P and
U waste codes (residuals from shipment of commercial chemical products).

Potential Recycling, Reclaim solvents in an onsite distillation unit for reuse or send for reclamation.
Treatment, and Reuse wastewater solutions as the first rinse of highly contaminated tanks or cars.
Disposal Methods Sell heels/residuals of commercial chemical products (CCPs) to a reclamation facility.
Use alkaline heels/residuals to neutralize acid wastes.
Use detergent CCP heels/residuals in future cleaning operations.
Treat aqueous heels/residuals and wastewaters in a wastewater treatment unit regulat-
ed by the Clean Water Act.
Package and label hazardous wastes for shipment using a hazardous waste
transporter to a hazardous waste TSDF.

Potential Pollution
Prevention Methods
Manage heels/residuals separately from each other to facilitate recycling.
Switch from washing processes using solvents or caustic solutions to steam cleaning
methods, nonhazardous detergents, or aqueous solvents.
Install a closed washing and rinsing system to recycle wastewaters, reduce water
usage, and limit volatile organic air emissions.
Use suction or vacuum pumps and squeegee the walls of tanks or cars to remove
heels/residuals more efficiently and reduce contamination of wastewaters.
Wash trucks or rail cars more frequently to prevent residue accumulation that could
make wash waters hazardous.

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Wastes
Minimize the amount of water used in washing operations.
Keep solvent containers covered to prevent product volatilization.
Use a first in, first out policy in storage areas and computerize inventory control to pre-
vent materials from expiring.

PROCESS Degreasing, Parts Washing, Rust Removal

Wastes Generated Ammonium hydroxide, benzene, chromic acid, hydrobromic acid, hydrochloric acid, hydrofluo-
ric acid, methylene chloride, mineral spirits, nitric acid, oil or grease, petroleum distillates,
phosphoric acid, potassium hydroxide, rags containing solvents or grease, sodium hydroxide,
sulfuric acid, toluene, toxic metals, volatile organic constituents, wastewaters, and sludges.

Possible RCRA D001 (benzene, methylene chloride, mineral spirits, oil or grease, petroleum distillates,
Waste Codes toluene, used rags), D002 (ammonium hydroxide, chromic acid, hydrobromic acid,
hydrochloric acid, hydrofluoric acid, nitric acid, phosphoric acid, potassium hydroxide, sodi-
um hydroxide, sulfuric acid, wastewaters), D007 (wastewaters, rags, contaminated sol-
vents), D008 (contaminated solvents, rags, wastewaters), D018 (contaminated solvents,
wastewaters), F001 or F002 (methylene chloride), and F005 (benzene, toluene).

Potential Recycling, Reclaim solvents in an onsite distillation unit for reuse or contract to have the solvents
Treatment, and shipped off site for recycling.
Disposal Methods Contact state or regional EPA office to determine the status of rags in your state.
Treat wastewaters in a wastewater treatment unit regulated by the Clean Water Act.
Package and label hazardous wastes for shipment using a hazardous waste
transporter to a hazardous waste TSDF.

Potential Pollution Replace solvent- and caustic-using parts washers with ultrasonic part washing systems,
Prevention Methods bake-off ovens, or detergent baths.
Substitute aqueous solutions for organic solvents.
Keep vehicles in good repair to prevent oil leaks.
Install drip racks over solvent sinks and increase drip time to reduce air emissions.
Apply solvents with a method other than spraying to avoid air emissions.
Close solvent containers and keep solvent sinks covered to prevent product volatilization.
Use dry precleaning methods such as wire brushing.
Use contaminated washing solutions as prerinse for dirty parts.

PROCESS Painting

Wastes Generated Alcohols, methyl ethyl ketone, methyl isobutyl ketone, methylene chloride, mineral spirits,
paint pigments, petroleum distillates, volatile organic compounds, wastewater, and xylene.

Possible RCRA D001 (alcohols, methyl ethyl ketone, methyl isobutyl ketone, methylene chloride, mineral
Waste Codes spirits, petroleum distillates, xylene), D007 (pigments), D008 (pigments), D035 (methyl ethyl

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